>>> Programme

The multilateral instrument (signed on 7 June 2017) is arguably the most significant event in terms of tax treaties since their early creation in the 1920s. For discussion is the question of the instrument’s impact and the future trend of tax treaties.

Speaker(s):

Dr Dumisani Jantjies

Parliamentary Budget Office

Annet Oguttu

Unisa

Charles Makola

EY

Prof. Deborah Tickle

KPMG

Anne Casey

Deloitte

Wally Horak

Bowmans

09:45 to 10:30

Small and Medium Businesses: Engine for Growth Versus the Tax Gap (Panel Discussion)

Small businesses are a vexing problem for government policymakers. On the one hand, small businesses are said to be the best engine for economic growth in terms of employment. On the other hand, small businesses pose the greatest challenge for the revenue authorities in terms of the tax gap. At issue is how to bridge this divide.

Speaker(s):

Veli Ntombela

SNG

Faith Ngwenya

SAIPA

SARS Representative

Deon van Zyl

PKF

10:30 to 11:00

Tea Break

11:00 to 11:45

Country-by-Country Reporting: Progress Update (Panel Discussion)

The new country-by-country reporting has been implemented for the first time and will create a sea change in international compliance. The initial challenges and questions arising will be discussed.

Much has been said about the global crackdown on offshore tax avoidance / evasion of multinational enterprises. This session will cover the heightened risks of this new environment as well as remaining options for manoeuvre.

Speaker(s):

Barbara Curson

Consultant

Ernest Mazansky

Werksmans Attorneys

Wayne Fuller

Old Mutual

Thabo Legwaila

Citibank & Davis Tax Committee

12:30 to 13:30

Lunch

13:30 to 14:00

The Tax and Exchange Control Implications of Shifting Intellectual Property Offshore (Solo Speaker)

The Reserve Bank has recently announced relaxation of exchange controls in terms of intellectual property. This session will cover the significance of this change in terms of exchange control and tax as well as key restrictions remaining.

Speaker(s):

Musa Manyathi

Deloitte South Africa

14:00 to 14:30

Tightening of the CFC Regime and Competitive Pressures (Mini-Panel Discussion)

Treasury has shown a propensity to tighten its tax grip on controlled foreign companies since the OECD announcement of BEPS. This session covers the practical impact of these changes, including the recent changes that tighten the diversionary rules.

Speaker(s):

Anne Bennett

Webber Wentzel

Prof. Osman Mollagee

PwC

Louise Vosloo

Deloitte

14:30 to 15:00

South African Debt Payments to Foreigners: Thin Cap and Other Limitations (Solo Speaker)

One long-standing issue in terms of cross-border payments is the deductibility of cross-border interest. Besides legislative changes, the rules of thin capitalisation have never been resolved since the revised draft interpretation note was issued. This session covers the current state of play.

Speaker(s):

Karen Miller

Webber Wentzel

15:00 to 15:30

Tea Break

15:30 to 16:30

Onus of Proof: What Level of Documents is Sufficient? (Town Hall Discussion)

Taxpayers must have documentation to support deductions, inputs and other claims against tax. The question presented is the level of documentation required to support these claims in terms of reasonableness so as to overcome revenue authority concerns relating to fraud.